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Issues: (i) Whether the law reports published by the respondent were "newspapers" within section 2(b) of the Act. (ii) Whether the employees engaged in their production or publication were entitled to the benefits under the Act and the orders made on the basis of the Palekar Award.
Issue (i): Whether the law reports published by the respondent were "newspapers" within section 2(b) of the Act.
Analysis: The statutory definition required a printed periodical to contain public news or comments on public news, besides any notified class of periodical. The law reports were printed periodicals and the decisive question was whether reports of recent judgments of the Supreme Court and High Courts amounted to public news or comments on public news. The Court treated decisions of superior courts as matters of public importance and held that information about recent judicial decisions is news to the public and to readers concerned with law and the administration of law. The fact that such reports may later be preserved as reference books did not alter their character when received by subscribers. The beneficial object of the Act also supported a construction advancing coverage of employees in newspaper establishments.
Conclusion: The law reports were newspapers within section 2(b) of the Act, against the respondent and in favour of the appellants.
Issue (ii): Whether the employees engaged in their production or publication were entitled to the benefits under the Act and the orders made on the basis of the Palekar Award.
Analysis: Once the publications were held to be newspapers, the respondent became a newspaper establishment and the persons employed in the production or publication of those reports fell within the statutory scheme. The Court accepted that the orders made by the Central Government on the basis of the Palekar Tribunal's recommendations applied to such employees. The Act being a beneficent legislation, its construction had to further the statutory purpose of improving service conditions of newspaper employees.
Conclusion: The employees were entitled to the benefits under the Act and the Palekar-based orders, against the respondent and in favour of the appellants.
Final Conclusion: The appeal succeeded, the High Court's judgment was set aside, and the writ petition filed by the respondent failed.
Ratio Decidendi: Publications containing recent judicial decisions of superior courts can constitute newspapers if they are printed periodicals carrying public news or comments on public news, and the Act must be construed purposively to advance its beneficent object in favour of newspaper employees.